IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. UNITED STATES OF AMERICA * * CRIMINAL NO. * v. * (8 US.C. §§ 2, 371, 981@)(C), 982, * 1001 (a), 1956(h), and 3551 et soq.; 22 PAUL J. MANAFORT, JR, and * USC. §§ 612(a), 618(a)(1), and RICHARD W. GATES UZ, * — 618(a)(2}; 28 U.S.C. § 2461(0); 31 U.S.C, * 88 5314 and 532200)) Defendants. * peeneee INDI ‘The Grand Jury for the District of Columbia churges: Case: 1:17-cr-00201 ° Assigned To ; Judge Jackson, Amy Berman ‘Assign. Date : 10/27/2017 Description: INDICTMENT (B) Introdw ALall times relevant to this Indictment I, Defendants PAUL J. MANAFORT, JR., (MANAFORT) and RICHARD W. GATES DIL (GATES) served for years as political consultants and lobbyists. Between at least 2006 and 2015, MANAFORT and GATES acted as unrogistered agents of the Government of Ukraine, the Party of Regions (a Ukrainian political party whose leader Victor Yanukovych was President from 2010 to 2014), Yanukovych, and the Opposition Bloc (a successor to the Party of Regions that formed in 2014 when Yanukovych fled to Russia). MANAFORT and GATES generated tens of millions of dollars in income as a result of their Ukraine work. In order to hide Ukraine payments fom United States authorities, from approximately 2006 through at least 2016, MANAFORT and GATES laundered the money through scores of United States and foreign corporations, partnerships, and bank accounts,2. In furtherance of the scheme, MANAFORT and GATES funneled millions of dollars in payments into foreign nominee companies and bank accounts, opened by them and their accomplices in nominee names and in various foreign countries, including Cyprus, Saint Vincent & the Grenadines (Grenadines), and the Seychelles. MANAFORT and GATES hid the existence of the foreign companies and bank accounts, falsely and repeatedly reporting to their tax preparers and to the United States that they had no foreign bank accounts. 3. In furtherance of the scheme, MANAFORT and GATES concealed from the United States their work as agents of, and millions of dollars in payments from, Ukraine and its political parties and leaders. Because MANAFORT and GATES, among other things, directed a campaign to lobby United States officials on behalf of the Government of Ukraine, the President of Ukraine, and Ukrainian political parties, they were required by law to report to the United States their work and fees. MANAFORT and GATES did not do so. Instead, when the Department of Justice sert inquiries to MANAFORT and GATES in 2016 about their activities, MANAFORT and GATES responded with a series of false and leading statements 4. In furtherance of the scheme, MANAFORTT used his hidden overseas wealth to enjoy a lavish lifestyle in the United States, without paying taxes on that income. MANAFORT, without reporting the income to his tax preparer or the United States, spent millions of dollars on tuxury goods and services for himself and his extended family through payments wired from offshore nominee accounts to United States vendors. MANAFORT also used these offshore accounts to purchase multi-million dollar properties: in the United States. MANAFORT then borrowed millions of dollars in loans using these properties as collateral, thereby obtaining cash in the United States without reporting and paying taxes on the income. In order to increase the amount of money he could access in the United States, MANAFORT defrauded the institutions that loaned money 2‘on these properties so that they would lend him more money at more favorable rates than he would otherwise be able to obtain, 5. GATES aided MANAFORT in obtaining money from these offshore accounts, which he was instrumental in opening. Like MANAFORT, GATES used money from these offshore accounts to pay for his personal expenses, including his mortgage, children’s tuition, and interior decorating of his Virginia residence. 6. In total, more than $75,000,000 flowed through the offshore accounts. MANAFORT Jaundered more than $18,000,000, which was used by him to buy property, goods, and services in the United States, income that he concealed from the United States Treasury, the Department of Justice, and others, GATES transferred more than $3,000,000 from the offshore accounts to other accounts that he controlled, 7. MANAFORT was @ United States citizen, He resided in homes in Virginia, Florida, and Long Island, New York. 8. GATES was a United States citizen. He resided in Virginia, 9, In 2008, MANAFORT and another partner created Davis Manafort Partners, Inc. (DMP) to engage principally in political consulting. DMP had staff in the United States, Ukraine, and Russia. In 2011, MANAFORT created DMP International, LLC (DMD to engage in work for foreign clients, in particular political consulting, lobbying, and public relations for the Government of Ukraine, the Party of Regions, and members of the Party of Regions. DMI was a partnership solely owned by MANAFORT and his spouse, GATES worked for both DMP and DMI and served as MANAFORT’s right-hand man. 10. The Party of Regions was a pro-Russia political party in Ukraine. Beginning in 3